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A-20) and explained that IA had gone through an important transition in the early 1990’s when it absorbed another insurance company with about 170 sales agents who were all considered independent contractors. ... She regularly reported to her sales manager and considered her a “coach”. ... He explained that sales were a function of the number of meetings and transactions per week. [108] Meeting with the sales manager were not considered compulsory but they were generally in high demand for advice and a second opinion. ...

As to the accident policies, the applicability of Section 3(1) (j) was to be considered without reference to any decisions bearing on the corresponding provision of the U.K. ... AS indicated, I have considered the matter on the assumption that the Ontario Insurance Act is applicable and on the basis that the deceased’s estate was nominated as beneficiary under the Group Policy. ... They cannot be considered “bakers’ biscuits” as intended by Schedule III. 3. ...

I infer from the evidence considered as a whole that the amount of Points purchased by Members for cash was nominal compared with the Points accumulated by Members in connection with spending on their Amex credit card. ... The accumulation of Points and the obtaining of Rewards is considered by MRP Cardholders to be an additional benefit. ... I considered a similar series of facts in my recent decision in PC Bank. ...

The Appellant filed its Answer to the Amended Reply on July 6, 2018. [8] In paragraph 35 of the Notice of Appeal, the Appellant says that the issues to be decided in the Appeal are: (a) Can the principal reason for the agreement of the partners of Action LMS LP to share partnership income and losses pro rata, based on the number of units held by each partner, reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable under the Act? ... However, having considered the explanations given by Mr. Thompson and the Appellant’s counsel for refusing to answer the Disputed Mindset Questions, I understand that they are of the view that those questions cannot be answered without disclosing privileged information. ... Putnam’s Sons, 1985), p. 339. [13] Situations where the courts have considered intent, purpose and motivation, when applying subsection 103(1) of the Act, are Penn West Petroleum Ltd. v. ...

She considered it illegal competition at the time because they were cutting the native person on the Reserve out of the supplies; (x) When she met with the CRA auditors, they told her of the consequences if she was an agent or if she was purchasing on her own account. ... She testified that only Roberta MacNaughton was considered to be the Lumsden customer, and not any of Roberta MacNaughton’s customers (or their customers). ... This issue was considered by Lumsden in the context of the steps it was considering for the collection of the approximate $320,000 Roberta MacNaughton owed Lumsden after the armed robbery at her store. [150] In this case, the Minister alleges that there was GST leakage within the supply chain for the sale of the Tobacco Products. ...

This statutory concept of “unduly’’ or “artifically” has been considered in many contexts, including so-called sham transaction and artificial transaction matters. ... Sham Transactions Sham transactions as considered in the cases appear to be transactions in which the taxpayer has used various technicalities or devices for the purpose of tax avoidance. ... This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income—including payment of a tax under the provisions of s 105(b) of the Act—had been weighed and rejected. ...

The Queen, 2018 TCC 182 where Miller J. considered whether the taxpayer was precluded from relying on certain arguments due to the application of the large corporation rules. ... Canada, 2002 SCC 28, where the Court turned its attention to the phrase, “in respect of” noting that although it suggests “a broad set of connections,” it is not of “infinite reach” and a “proper approach to statutory interpretation” requires that the entire context be considered. ... I reject the notion that RBC was involved in an endeavour. [115] In Amex Bank, Hogan J. considered the bank’s claim for ITCs on the redemption of reward points and concluded that they were “incurred in respect of a liability that arose because of the supply of an exempt financial service” (para. 75). ...

McNeilly and tendered those agreements as exhibits. [31] These are all factors that may be considered in the proportionality analysis. [32] [58] I acknowledge that, with any confidentiality order, there will likely be some impact on the open court principle. [33] However, having considered the above factors, I am of the view that the desired confidentiality order represents a relatively minimal intrusion into the principle of court openness, such that it would not have a significant deleterious effect on that principle. [34] (4) Decision [59] Accordingly, I allowed the motion and granted a confidentiality order under section 16.1 of the Rules. ... Liu confirmed that, at her clinic, Mount Sinai Fertility, an intended parent is considered to be a patient. [67] [112] I accept Dr. ... McNeilly was the patient in the context of many of the procedures, tests and other services that she considered, and that were performed by Create or Kiran, but I limit that opinion to a medical or clinical context. ...

It follows that excluding an instrument from the ambit of the word debt simply because the amount which can ultimately be claimed will only be known when the term expires would effectively mean that Parliament has spoken in vain in providing for a “debt […] that may reasonably be considered to derive its value […] from portfolio investments”. ... I agree with the Tax Court judge that the reference to interest in the Notes, even if zero is the amount to be considered for this purpose, can be indicative of a debt as loans are often described as “no interest” or “interest-free” (Barejo 2015, paras. 131 and 133(v)). ... This comment was likely prompted by the general nature of the question that he initially considered. ...

This is the first time that this Court, or any Canadian court, has considered section 143 of the Income Tax Act (the “ Act ”) ... Chaplains in hospitals, jails, the armed forces and other such organizations are generally considered to minister to congregations.   ... In the 1942 Declaration of Trust document, only the current trustees, not community members generally, were to be considered beneficiaries of the consecrated trust property. ...